STIPULATION FOR EXTENSION OF DEADLINE TO FILE RULE 26 JOINT DISCOVERY PLAN

1ST REQUEST TO EXTEND DEADLINE TO SUBMIT RULE 26 JOINT DISCOVERY PLAN

CARL W. HOFFMAN, District Judge.

Defendant Green Tree Servicing LLC, now known as Ditech Financial LLC ("Ditech") and Plaintiff Lee C. Kamimura ("Plaintiff"), collectively referred to herein as the "Parties," hereby stipulate to the following:

1. Plaintiff filed her Class Action Complaint For Damages Pursuant To The Fair Credit Reporting Act, 15 U.S.C. § 1681, Et Seq. ("Complaint") against Defendant on April 8, 2016.

2. On May 2, 2016, Plaintiff filed a First Amended Complaint.

3. Plaintiff served Ditech with the First Amended Complaint on May 10, 2016.

4. On June 30, 2016, Ditech filed its motion to dismiss Plaintiff's First Amended Complaint.

5. The Parties have held their discovery conference under Fed. R. Civ. P. 26(f) within 30 days after Ditech's motion to dismiss.

6. On July 15, 2016, Plaintiff filed a Second Amended Complaint ("SAC"). ECF NO. 16.

7. Ditech's response to Plaintiff's SAC is due on August 22, 2016. ECF No. 18.

8. After meeting and conferring regarding discovery, the parties have agreed to stipulate to extend the deadline to submit their stipulated discovery plan and scheduling order to forty-five (45) days after Ditech has filed an answer to the SAC.

9. Due to the changing nature of the pleadings, the possibility of further dispositive motions that may narrow the issues in the case, and the parties' willingness to cooperate on efforts to streamline discovery in this matter, good cause exists to delay extend the deadline for the Parties to submit a proposed discovery plan until after Ditech has responded to the SAC.

10. This is the first stipulation for extension of the deadline to file a proposed discovery plan.

IT IS SO STIPULATED.